KFF Shares Findings on State Work Requirement Policies

The Kaiser Family Foundation (KFF) on April 30 released findings on early state policy decisions to implement community engagement requirements mandated by the Working Families Tax Cut legislation (WFTCL). The WFTCL requires enrollees and applicants in the Medicaid expansion group and those in partial Medicaid expansion waiver programs to meet work requirements to maintain Medicaid eligibility.

Forty-three states are required to implement these requirements by Jan. 1, 2027, but can implement them earlier. KFF found many states are planning to implement less restrictive policies and automated verification where possible:

• Four states-Arkansas, Idaho, Indiana, and New Hampshire-plan to adopt more restrictive compliance verification policies than required by law, two of which will conduct more frequent compliance checks.
• Iowa, Montana, and Nebraska plan to implement work requirements earlier than required by law.
• Eighteen states will use new data sources to further automate work requirement verification.
• Most states indicate they will use Medicaid claims data and other data sources to automate the process. Many states would like to allow self-attestation from enrollees and applicants.
• Twenty-nine states plan to adopt at least one of four hardship exceptions. Iowa and Indiana do not plan to adopt any hardship exceptions.

States are waiting for the federal rule to be published to implement several of these policies while they experience resource constraints, such as costs and staff capacity.

The Centers for Medicare and Medicare Services are required to publish rulemaking to implement the community engagement requirements by June 1, 2026.

Contact Director of Policy Rob Nelb, MPH, at [email protected] or 202.585.0127 with questions.